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Ireland – Raising the Bar, Squeezing Options for Immigrant Investor Programme

Ireland – Raising the Bar, Squeezing Options for

This GMS Flash Alert reports on important changes made to Ireland’s Immigrant Investor Programme that in several respects make this programme more costly.

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Significant changes have been made to Ireland’s Immigrant Investor Programme that raise the minimum amounts that need to be invested, as well as the application fees, for persons seeking Irish immigration rights through this programme.

The programme facilitates investors and business professionals from outside of the European Economic Area (“EEA”) to avail of opportunities for investing and locating business interests in Ireland.

WHY THIS MATTERS

It will become more challenging for some foreign nationals to enter Ireland under this programme, with the elimination of other avenues for achieving residency under this programme (Immigrant Investor Bond and Mixed Investment options) and the increase by 100 percent of the minimum investment amounts required to be eligible. 

Immigration counsel, clients, corporate finance, and investment fund advisers need to be aware of the changes that will impact any Immigrant Investor Programme applications currently in the preparatory stages. 

Immigrant Investor Programme – Background

The Immigrant Investor Programme (the “IIP”) was created by the Irish government to facilitate investors and business professionals from outside of the EEA to avail of opportunities for investing and locating business interests in Ireland.  The IIP provides an opportunity to non-EEA nationals and their families who commit to an approved investment in Ireland to acquire a secure residency status in Ireland. 

Changes to the IIP

A number of changes to the IIP have been announced by the Irish Naturalisation and Immigration Service with immediate effect:

  • Suspension of the Immigrant Investor Bond and Mixed Investment options;
  • Increase in the minimum investment for the Enterprise Investment option from €500,000 to €1,000,000;
  • Increase in the minimum investment for Investment Funds option from €500,000 to €1,000,000; and
  • Increase in the IIP application fee and deadlines for acceptance of applications by the Evaluation Committee.

Suspension of Immigrant Investor Bond and the Mixed Investment Option

The Immigrant Investor Bond and the Mixed Investment option have been suspended with immediate effect.  The Irish Naturalisation and Immigration Service has advised that until such time as there is a review conducted on the Immigrant Investor Bond and the Mixed Investment option, there is no proposal to re-open these IIP options.1  

Increase in Minimum Investment for the Enterprise Investment and Investment Fund

The minimum investment requirement for the Enterprise Investment IIP option has increased from€500,000 to €1,000,000.  This IIP option requires a minimum investment of €1,000,000 in either a single Irish enterprise or spread over a number of enterprises for a minimum of three years.  The enterprise may be a start-up established by the investor or an existing business; however it must be registered and headquartered in Ireland and must support the creation or maintenance of employment.  This IIP option is suitable for investors who wish to create a new enterprise or invest in an existing business in Ireland.  It will also facilitate investors who have their own investment or business strategy and see the benefits of Ireland as a location in which to invest and do business.2  

Similarly, the minimum investment requirement for the Investment Fund IIP option has increased from €500,000 to €1,000,000.  This IIP option requires a minimum investment of €1,000,000 in investment funds which have been approved for the purposes of the Immigrant Investor Programme by the Irish Naturalisation and Immigration Service.  The investment must be for a minimum of three years.3  This option allows investors to avail of the service of approved professional investment intermediaries to invest in the future potential of Ireland’s enterprise sector.4  

Changes to IIP Application Fee and Deadline for Acceptance of Applications by Evaluation Committee

The IIP application fee has increased from €750 to €1,500.  Each IIP application must be submitted to the Evaluation Committee in the Irish Naturalisation and Immigration Service.  The Evaluation Committee will sit five times this year to assess IIP applications.  The time periods for IIP submissions for 2017 are as follows:  

  • 02/01/2017 - 27/01/2017;
  • 20/03/2017 - 13/04/2017;
  • 22/05/2017 - 16/06/2017;
  • 14/08/2017 - 08/09/2017;
  • 16/10/2017 - 10/11/2017.

Applications received outside of these periods will be returned.  Applications with the incorrect fee or investment amount will also be returned.  

KPMG NOTE

Applications under the above-mentioned IIP options that are affected by this change and have not yet been filed with the Evaluation Committee may need to be revised.  Affected parties should consult with their qualified Irish employment law adviser and/or immigration counsel for further guidance on this point. 

FOOTNOTES

1  For additional information, see the Irish Naturalisation and Immigration Service webpage. 

2  This is according to guidance (PDF 594 KB) provided by the Irish Naturalisation and Immigration Service webpage. 

3  Further guidance and requirements (PDF 276 KB) are detailed on the Irish Naturalisation and Immigration Service webpage. 

4  This is according to guidance (PDF 594 KB) provided by the Irish Naturalisation and Immigration Service webpage. 

Please note that KPMG LLP (U.S.) does not provide immigration or labour law services. 

The information contained in this newsletter was submitted by the KPMG International member firm in Ireland.

© 2017 KPMG, an Irish partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

Flash Alert is an Global Mobility Services publication of KPMG LLPs Washington National Tax practice. The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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